RoHS for Smart Luggage: The 10 Substances and How to Read the Report

RoHS compliance series. This article is the 10 restricted substances and how to read the smart-luggage report. Start at the hub: What RoHS Actually Is: Directive 2011/65/EU Explained.

The moment a suitcase learns a trick — USB charging, a motor, lights — it stops being just luggage and becomes electrical and electronic equipment. That's not a marketing shift. It's a regulatory one.

RoHS — the Restriction of Hazardous Substances Directive 2011/65/EU — limits ten substances in electrical and electronic equipment sold in the EU: lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates added by Directive (EU) 2015/863.

Once your suitcase includes electronics, the proof is a laboratory report using the EN/IEC 62321 test series. Our Model 1338 report (No. S250827030001-1, September 2025) screened the non-metal material, and all ten substances came back not-detected, leading to the Certificate of Conformity (No. S250827030001-2).

What RoHS Does

RoHS restricts specific hazardous substances in electrical and electronic equipment (EEE). The idea is simple: electronics contain metals, flame retardants and plasticizers that are hazardous in production and disposal, so the EU caps their concentration in each homogeneous material.

Unlike REACH, which manages SVHC communication across all articles, RoHS is a hard restriction with defined limits — and it is one of the directives behind CE marking for EEE.

The Ten Substances in One Table

Substance group	Substances	Limit
Heavy metals	Lead (Pb), Mercury (Hg), Hexavalent chromium (Cr VI)	1000 mg/kg (0.1%)
Heavy metal	Cadmium (Cd)	100 mg/kg (0.01%)
Flame retardants	Polybrominated biphenyls (PBBs), Polybrominated diphenyl ethers (PBDEs)	1000 mg/kg (sum)
Phthalates (since (EU) 2015/863)	DEHP, BBP, DBP, DIBP	1000 mg/kg each

The four phthalates were added to Annex II in 2015 and became mandatory for most EEE in July 2019 — which is why "RoHS 10" is now the standard scope.

The Test Summary, Read in One Minute

Report element	What it tells you
Report No. S250827030001-1	Unique ID; the certificate cites the same number
Sample: Multi-function trolley box, Model 1338	The exact tested product — same model as our EMC report
Tested material: grey fabric (non-metal)	The scope of this submission — non-metal material
Standard: 2011/65/EU + (EU) 2015/863	RoHS 2 with the phthalate amendment
Methods: EN 62321 series	The harmonized test methods (equivalent to IEC 62321)
Result	All ten substances N.D. — pass
Certificate No. S250827030001-2	The conformity conclusion based on the report

Report vs Certificate

The report is the laboratory evidence — every substance, limit, method and result line. The Certificate of Conformity is the summary conclusion. It carries the same honest note as our other certificates: it is based on a single evaluation of one sample, it does not imply an assessment of the whole production, and it does not permit use of the test lab's logo. The report proves the sample; production control keeps the sample representative.

What This Report Does NOT Cover

Honest boundaries, because the limits of a document are as important as its conclusions:

It covers the non-metal material submitted — the grey fabric of Model 1338. Metal components and other non-metal materials are outside this submission and need their own scope (Article G5 explains the split).
RoHS is EU. Other markets have their own electronics substance rules.
RoHS is one directive among several. EMC (our E-series article), REACH (our F-series article) and other CE-relevant directives sit alongside it.
One sample, one configuration. Change materials, suppliers or components and the evidence needs revisiting.

Frequently Asked Questions

What does RoHS stand for?

Restriction of Hazardous Substances — Directive 2011/65/EU, which limits ten substances in electrical and electronic equipment placed on the EU market.

Does RoHS apply to luggage?

Only to luggage with electronics. A purely mechanical suitcase is outside scope; once you add USB charging, lights, a motor or a scale, the electronics bring RoHS obligations.

What are the ten RoHS substances?

Lead, mercury, cadmium, hexavalent chromium, PBBs, PBDEs, and four phthalates (DEHP, BBP, DBP, DIBP) added by Directive (EU) 2015/863.

What are the RoHS limits?

1000 mg/kg (0.1%) for most substances, 100 mg/kg (0.01%) for cadmium, and 1000 mg/kg for the summed PBB/PBDE and each phthalate.

Is a RoHS report the same as a REACH report?

No — RoHS is a hard restriction on ten substances in EEE; REACH manages SVHC communication across all articles. An electronic product in the EU may need both, plus EMC.

How do I know a factory's RoHS report is current?

Check the standard versions (the EN 62321 series with their amendment years), the sample and model, the date, and the certificate's report number. Article G8 is the full verification checklist.

About the Author

Written by the CLK Manufacturing Team — 16+ years of custom luggage OEM/ODM experience from our factory in Ji'an, Jiangxi, China. Updated: 2026-08-15.